giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…cs Codo, Sections 1591(aX1) and 2; and
IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
liability and Epstein undentands and acknowledges that, in exchan&e for the benefits
provided by this agreement, he agrees…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…560, 562–66 (C.D.Cal.2012)
(ordering alternative service and noting that service of defendant under the Hague Convention
would take four to six months); Ackerman v. Global Vehicles U.S.A., Inc., 2011 WL 3847427, at
1
C…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…resolve this case.
8 I am not looking for any tactical delay here. I am just
9 looking for a reasonable solution to what I see as a global
10 problem.
11 THE COURT: OK. Let me ask you this…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…involved, such as the “TerraMar
Project or any other not-for-profit entities with which You are associated, including but not
limited to, funding received from the Clinton Global Initiative, the Clinton Foundation (a/k/a
William J. Clinton Foundation…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…involved, such as the “TerraMar
Project or any other not-for-profit entities with which You are associated, including but not
limited to, funding received from the Clinton Global Initiative, the Clinton Foundation (a/k/a
William J. Clinton Foundation…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
…resolve this case.
8 I am not looking for any tactical delay here. I am just
9 looking for a reasonable solution to what I see as a global
10 problem.
11 THE COURT: OK. Let me ask you this…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…for Ms. Giuffre said at the
time:
1111
There is absolutely no reason why my client should reasonably anticipate that her
sex abuser would defame her in the global stage at that point [when she held the
bonfire]. She is…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…are found in documents Bates labelled GIUFFRE000001 to
GIUFFRE007566.
6. Identify any “false statements” attributed to Ghislaine Maxwell which were
“published globally, including within the Southern District of New York” as You contend in
paragraph 9 of Count I of…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…by newspaper and other media outlets internationally, and they
were, in fact, published globally, including within the Southern District of New York.
10. Maxwell’s false statements constitute libel per se inasmuch as they exposed
Giuffre to public contempt, ridicule…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…Ms. Maxwell interposed Interrogatories concerning which “false statements”
attributed to Ms. Maxwell were “published globally” as contended in paragraph 9 of Count 1 of
the Complaint (Interrog. No. 6) and whether Plaintiff has been defamed by anyone other than
1…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…claims.”).
Interrogatory No. 6. Identify any “false statements” attributed to Ghislaine
Maxwell which were “published globally, including within the Southern District
of New York” as You contend in paragraph 9 of Count 1 of Your Complaint,
including:
a. the exact…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…by newspaper and other media outlets internationally, and they
were, in fact, published globally, including within the Southern District of New York.
10. Maxwell’s false statements constitute libel per se inasmuch as they exposed
Giuffre to public contempt, ridicule…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…by newspaper and other media outlets internationally, and they
were, in fact, published globally, including within the Southern District of New York.
10. Maxwell’s false statements constitute libel per se inasmuch as they exposed
Giuffre to public contempt, ridicule…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…New Mexico; (d) U.S. Virgin islands; (e)
any jet or aircraft owned or controlled by Jeffrey Epstein.
Request Number 33 appears to be subsumed by the globally inclusive, unrestricted
Request Number 8. Both requests fail in many ways. First…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…https://www.dailymail.co.uk/news/article-8872327/Jeffrey-Epstein-told-Ghislaine-Maxwell-reward-discredit-Virginia-Roberts.html
104 https://globalnews.ca/news/7412928/ghislaine-maxwell-transcript-jeffrey-epstein/
105 https://in.reuters.com/article/people-ghislaine-maxwell/ghislaine-maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…For instance, Interrogatory No. 6 directs Ms.
Giuffre to “[i]dentify any ‘false statements’ attributed to Ghislaine Maxwell which were
‘published globally’ … as You contend in … Your Complaint[.]” Interrogatory No. 8 directs Ms.
Giuffre to identify, among other…
giuffre-maxwell
gov.uscourts.nysd.447706.983.0
24 pg
…5 In my view, your Honor, there should be -- the parties
6 should identify globally what I would call category one,
7 category two and category three documents. Category one would
8 be non-judicial documents; category two would be…
giuffre-maxwell
gov.uscourts.nysd.447706.75.0
31 pg
…propounded discovery.
15
Case 1:15-cv-07433-LAP Document 75 Filed 03/31/16 Page 21 of 31
information that she has globally shared and sold to media publications or is actively trying to
sell for a profit…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…claims.”).
Interrogatory No. 6. Identify any “false statements” attributed to Ghislaine
Maxwell which were “published globally, including within the Southern District
of New York” as You contend in paragraph 9 of Count 1 of Your Complaint,
including:
a. the exact…
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